Category: Process Safety

Pursuant to Executive Order (EO) 13650 “Improving Chemical Facility Safety and Security”, OSHA was directed to modernize their Process Safety Management of Highly Hazardous Chemicals (PSM) standard (29 CFR 1910.119). OSHA has issued potential revisions to the standard and convened a Small Business Advocacy Review (SBAR) Panel earlier this year. The Small Business Regulatory Enforcement Fairness Act (SBREFA) Panels were conducted back in June 2016, with the completed report placed in the federal docket on August 1, 2016.

OSHA has extended the compliance deadline to July 22, 2016 for those affected facilities previously considered exempted retail facilities under the PSM regulation. In July 2015, OSHA revised the PSM retail exemption interpretation to only exempt those facilities under NAICS codes 44 and 45. As part of this change, those affected facilities are will also required to update their EPA RMP programs from level 2 to level 3.

On December 3, 2015, the International Institute of Ammonia Refrigeration (IIAR) published the new ANSI/IIAR 2-2014: American National Standard for Safe Design of Closed-Circuit Ammonia Refrigeration Systems. This standard replaces the 2008 edition of the standard. This is IIAR’s first comprehensive safety standard and was written specifically for adoption by code making bodies. This change sees the new standard written using enforceable language. Informative topics and guidance are now included in appendices. Historically, ANSI/IIAR 2 has served as the recognized and generally acceptable good engineering practices (RAGAGEP) for safe design and compliance for ammonia refrigeration facilities subject to the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) and the Environmental Protection Agency’s (EPA) Risk Management Plan (RMP). This won’t change with the new standard; however, we could see a more formal adoption of the standard by OSHA and EPA.

On January 18, 2016, the National Fire Protection Association (NFPA) published the 2nd draft report for NFPA 499: Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas. It is now open for a Notice of Intent to Make a Motion (NITMAM) until February 19, 2016 for those on a Committee Comment, Second Revision, or Second Correlating Revision. The purpose of NFPA 499 is to provide information on classifying combustible dusts and locations and provide recommended practices on proper selection of electrical equipment in hazardous (classified) locations per NFPA 70, National Electrical Code. NFPA 499 is a compendium document to Chapter 5 (Article 500) of NFPA 70 and does not supersede any requirements of other NFPA standards (e.g. NFPA 61, 68, 69, 654, 664, etc.).

The EPA’s Risk Management Plan (RMP) regulation (40 CFR Part 68) was issued in multiple stages, beginning in 1994. The regulation was modeled after OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119). The RMP regulation is about reducing chemical risk at the local level. The information from the RMP aids local fire, police, and emergency response personnel in responding to chemical accidents. It also helps citizens to understand the chemical hazards in their communities. The regulation has been left relatively unchanged since its issuance.

Today, during the Technical Meeting at NFPA’s 2015 Annual Conference, there were two certified motions up for a vote related to the new NFPA Standard on Fundamentals of Combustible Dust – NFPA 652. One motion was to remove the requirement for a Dust Hazard Analysis, and the other was to delay the issuance of the Standard completely. Both motions were defeated by an overwhelming majority of the NFPA voting members, including myself. These votes were the last hurdle in the issuance of the Standard later this year.

NFPA 652 is the first step in developing a single, overarching standard to deal with fire and explosion hazards associated with combustible dust of all types and in all industries. Currently, there are several industry and commodity specific standards, such as NFPA 61 for agricultural dust and 664 for wood dust, that often lack consistency, leading to confusion among users, authorities having jurisdiction (e.g. OSHA), and safety professionals. The development of NFPA 652 intends to alleviate some of the confusion … eventually. Over the coming months, CTI will be writing articles, providing presentations at conferences and online, and consulting our clients with the specifics of the standard. If you are interested in staying in touch with these developments and other news, please email cti@conversiontechnology.com and ask to be included on our Newsletter list.

When dealing with processes involving combustible dust, flammable liquids & gasses, and extremely toxic materials, understanding the hazards in the process is critical. This is true when designing a new process, as well as when a plant changes equipment, chemicals, and procedures. Many of the most severe industrial accidents have occurred because the facility failed to consider how changes would impact process safety. That is why a robust management of change (MOC) procedure that incorporates process hazard analysis (PHA) is so important. Continue reading “The Importance of Management of Change and Hazard Analysis”→

For several years, NFPA has been working to develop NFPA 652, Fundamentals of Combustible Dust. According to Guy Colonna’s recent article in NFPA Journal, the standard is due out this summer(1). This standard will be an overarching standard that applies to all facilities where combustible dust or particulate solids are present. CTI will provide detailed information once the final standard is released. Brian Edwards, PE of CTI has attended the development meetings for that standard, and he is available to answer any questions you may have about the new standard, or the existing, industry-specific standards.